Review of the Compliance Guide HACCP Systems Validation Public Meeting June 25, 2013 Washington, DC Dr. William Shaw Risk, Innovations & Management Staff

HACCP Final Rule Pathogen Reduction; Hazard Analysis and Critical Control Point (HACCP) Systems; Final Rule Published on July 25, 1996 Validation regulatory language: – 9 CFR Validation, Verification, Reassessment Also included the Agency’s position on how the regulatory language should be implemented Both pieces of information will guide FSIS’ implementation policies 6/25/20132HACCP Systems Validation Public Meeting

Need for Guidance FSIS has determined from its HACCP verification activities that many establishments have not properly validated their systems. Inadequate validation has been linked to food safety problems: – Chicken pot pie outbreaks in 2007; – 2011 Lebanon bologna outbreak; and – Analysis of non-O157 positives in /25/20133HACCP Systems Validation Public Meeting

Compliance Guide Development March, 2010 – Initial draft guidance posted receiving over 2000 comments June, 2010 – First public meeting Sept , 2011 – Second draft shared with the National Advisory Committee on Meat and Poultry Inspection (NACMPI) May, 2012 – Third draft guidance posted – Request for comment on draft published in the Federal Register – Federal Register Notice and third draft guidance addressed comments received on initial draft 6/25/20134HACCP Systems Validation Public Meeting

Recent Comments 51 comments were received on the May 2012 revised draft guidance. Comments were received from small and very small meat or poultry processors, trade associations representing animal producers, small business owners, corporations, State Departments of Agriculture, and consumer advocacy organizations. 6/25/20135HACCP Systems Validation Public Meeting

Current Draft May 29, 2013 – Fourth draft guidance posted Clarifies previous draft in response to public comments June 25, 2013 – Second and final public meeting 6/25/20136HACCP Systems Validation Public Meeting

Next steps Following today’s public meeting, the Agency will accept written comments until July 25, FSIS will addresses comments as necessary; however, the Agency believes that few changes, if any, will be made given the extensive opportunity for comment on the guidance. 6/25/20137HACCP Systems Validation Public Meeting

Updates to the Compliance Guide HACCP Systems Validation Public Meeting June 25, 2013 Washington, DC Dr. Meryl Silverman Risk, Innovations & Management Staff

Overview The two major elements of validation are the same: – The scientific or technical support for the HACCP system design (design), and – The initial practical in-plant demonstration proving the HACCP system can perform as expected (execution) Clarifications were made in response to public comments, but the main concepts have not changed. 6/25/20139HACCP Systems Validation Public Meeting

Areas of Clarification Two elements of initial validation Types of scientific support Application and matching of scientific support to actual processes How to select a product to gather execution data for within a HACCP category Initial validation vs. ongoing verification Need for guidance document 6/25/201310HACCP Systems Validation Public Meeting

Two Elements Principles remain the same. Elements have been summarized in succinct steps. Added graphic to illustrate two elements of validation. Element 1: Scientific or Technical Support (Design) Identify supporting documentation that closely matches the actual process (e.g., published processing guidelines, journal articles, challenge studies, etc.); Identify supporting documentation that demonstrates the expected level of bacterial pathogen reduction; and Identify the critical operational parameters from the supporting documentation relevant to the establishment's commercial process Element 2: Initial In- plant Demonstration (Execution) Implement the same critical operational parameters from the supporting documentation in the actual production process; Identify at least one product from each HACCP category to gather in-plant validation data; and Gather data demonstrating the effectiveness of the implementation of the critical operational parameters in-plant for such products. 6/25/201311HACCP Systems Validation Public Meeting

Element 1: Scientific or Technical Support Key steps are now summarized. To meet the first element of validation, establishments should: – Identify supporting documentation that closely matches the actual process (e.g., published processing guidelines, journal articles, challenge studies, etc.); – Identify supporting documentation that provides adequate support for the hazard identified in the hazard analysis; and – Identify the critical operational parameters from the supporting documentation relevant to the establishment's commercial process. 6/25/201312HACCP Systems Validation Public Meeting

Types of Scientific Support Information has been added on using pathogen modeling programs as a type of scientific support. Examples of incomplete scientific support for validation have been clarified. Specifically, cases where the supporting documentation should contain microbiological data for the same hazard listed in the hazard analysis are highlighted (i.e., interventions used during slaughter). 6/25/201313HACCP Systems Validation Public Meeting

Identifying Scientific Support Documents An additional section has been added further explaining how to identify that scientific support documents are sufficiently related to the process, product, and hazard identified in the hazard analysis. Also added ways in which an establishment can identify supporting documentation that adequately addresses the expected level of hazard or reduction or prevention to be achieved. 6/25/201314HACCP Systems Validation Public Meeting

Matching Scientific Support Documents New examples are given for biological, physical, and chemical hazards, which should aid establishments in ensuring that the scientific support closely matches the hazard being controlled. For biological hazards, limited cases where microbiological data specifying the expected level of reduction of one pathogen may be used to support the control of another pathogen are clarified. Specifically, the following cases are discussed: – non-O157 – Salmonella in ready-to-eat products 6/25/201315HACCP Systems Validation Public Meeting

Key Question on Appendix A Added Question: Can an establishment use Appendix A, which was designed to address Salmonella, to support other pathogens such as E. coli O157:H7 or Listeria monocytogenes are controlled? Answer: Yes, an establishment can cite Appendix A as support that E. coli O157:H7 and Listeria monocytogenes are controlled as a result of a thermal process. Although Appendix A was developed based on experiments measuring the efficacy of thermal processes on Salmonella, Salmonella can be used as an indicator of lethality for other pathogens such as E. coli O157:H7 and Listeria monocytogenes. 6/25/201316HACCP Systems Validation Public Meeting

Indicator or Surrogate Organisms The guidance also clarifies when it is appropriate to use scientific support containing data from indicator or surrogate organisms. Specifically, if similar and consistent reduction or control can be established, then control of the indicator organisms can be reliably used to indicate expected pathogen control in actual application. 6/25/201317HACCP Systems Validation Public Meeting

Element 2: Initial In-plant Demonstration Data Key steps are now summarized. To meet the second element of validation, establishments should: – Implement the critical operational parameters in the supporting documentation; – Identify at least one product from each HACCP category to gather in-plant validation data for; and – Gather data demonstrating the effectiveness of the implementation of the critical operational parameters in- plant for those select products. 6/25/201318HACCP Systems Validation Public Meeting

In-plant data The revised guidance adds numerous examples of food science principles that may be used to decide which product within a HACCP category should be used to gather execution data. While the list of examples is not meant to be exhaustive, the examples illustrate the importance of collecting execution data for a wide variety of products and worst case scenarios. EXAMPLE CRITERIA FROM THE GUIDELINE Fat content: Fat level in meat has been documented to influence bacterial heat resistance (Juneja et al., 2001). As the fat level increases, bacterial heat resistance increases. Therefore, higher fat content meat or poultry products require greater time or temperatures to achieve equal lethality compared with lower fat content products. – How this criterion could be used: If an establishment produces several fully cooked poultry products, the establishment should gather data for the product with the highest fat content. Similarly, if an establishment produces several ground poultry products, and some of the products are made from skin-on thigh meat while others are made with boneless, skinless thigh meat, the establishment should collect in-plant demonstration data for the ground product made from the skin-on thigh meat because of the additional fat from the skin. 6/25/201319HACCP Systems Validation Public Meeting

Types of In-plant Data Additional clarification is provided on the types of in-plant data that should be collected. That is, in cases where the establishment’s process is: – Implemented consistent with the process specifications described in the supporting documentation, and – When the scientific supporting documentation used contains microbiological data specifying the level of pathogen reduction achieved by the intervention strategy for the target pathogen identified in the hazard analysis, the establishment should: Demonstrate that the critical operating parameters are being met by gathering in-plant data e.g., data on quantifiable characteristics of the critical operational parameters such as pressure, temperature, and concentration. 6/25/201320HACCP Systems Validation Public Meeting

Types of In-plant Data In cases where the establishment’s process is: – Not implemented in a manner that is consistent with the process specifications described in the supporting documentation without justification, or – When the scientific supporting documentation used does not contain microbiological data specifying the level of pathogen reduction achieved by the intervention strategy for the target pathogen identified in the hazard analysis, the establishment should: Validate that the modified critical operating parameters are being met, AND Validate the intervention’s effectiveness under actual in-plant conditions. 6/25/2013HACCP Systems Validation Public Meeting21

Clarification of “Consistent with” Implementing process specifications consistent with the establishment’s process means that changes among the critical operational parameters used in the scientific support and those used in the actual process will not affect the efficacy of the intervention or treatment. 6/25/2013HACCP Systems Validation Public Meeting22

Initial validation vs. on-going verification The revised guidance reiterates the distinct functions of initial validation and on-going verification and the relationship between the activities performed as part of initial validation and on-going verification. The revised guidance also clarifies cases when changes that result from reassessment would not require validation (e.g., a change in a raw material may not require validation). 6/25/201323HACCP Systems Validation Public Meeting

Reassessment The revised guidance also addresses the new reassessment requirements in 9 CFR 417.4(a)(3)(i). NOTE: Official establishments are to make a record of each reassessment required by 9 CFR 417.4(a)(3)(i). The regulations require establishments to document the reasons for any changes to the HACCP plan based on the reassessment or the reasons for not changing the HACCP plan based on the reassessment. For annual reassessments, according to the regulation, if an official establishment determines that it does not need to make changes to its HACCP plan, it is not required to document the reasons for not changing the HACCP plan. 6/25/201324HACCP Systems Validation Public Meeting

Appendix 1: Examples of Food Safety Problems Linked to Inadequate Validation Added to explain the need for validation and FSIS's experiences that led to the creation of the guidance document. Specifically, FSIS’s findings from the following data analyses and outbreak investigations are summarized: – 2011 Lebanon bologna outbreak; – Analysis of non-O157 positives in 2012; and – Chicken pot pie outbreaks in /25/201325HACCP Systems Validation Public Meeting

Appendix 2: Example Decision-making Document Added to provide an example of a decision- making document an establishment could develop when it uses different levels of a critical operational parameter than those in the support document. The decision-making document may be used by an establishment to explain the scientific rationale for why the different level would not affect the efficacy of the intervention or process. 6/25/201326HACCP Systems Validation Public Meeting

Appendix 3: Guidance to Identify Critical Operational Parameters Some text was moved from the Appendix to the body of the document to focus on reviewing the organization of journal articles. No other changes were made to the remainder of the Appendix. 6/25/201327HACCP Systems Validation Public Meeting

Appendix 4: Validation Worksheet Examples An additional example was added to Appendix 4 with validation worksheet examples. The example illustrates the use of Appendix B and pathogen modeling as scientific support for a roast beef stabilization process. The example also includes the type of in-plant data that would be collected. 6/25/201328HACCP Systems Validation Public Meeting

Summary The main concepts of validation have not changed; however, as a result of public comments clarifications have been made to help improve understanding of these concepts. 6/25/2013HACCP Systems Validation Public Meeting29